Our commitment to you is that we will respect any personal data you share with us, or that we get from other organisations, and keep it safe. We aim to be clear when we collect your data and not do anything that you would not reasonably expect. We only ask for information that will inform our engagement with you personally and provide vital statistical data to underpin research and campaigning for better support for those living gluten free. Your participation in research could be essential in understanding more about the disease, developing treatments and finding a cure.
Please read the following information to understand how we collect your data, the purpose of collecting it and how we process it. We will notify you of any changes to our privacy policy via our website and member communications.

The data we collect:
We collect some or all of the following information from you, or via third parties where you have consented to them sharing the data with us or from publicly available information.

From you:
Name, address, email, date of birth, health information, behavioural data from voluntary surveys and bank or card information where you buy our services and products. When on our website, we will use your IP address, cookies and services like Google Analytics and other statistical services to record your activity on our website to help improve the site and services to you.

Types of Information

• Personal Identification Information – forms
  This is data that identifies you or can be used to identify or contact you and may include your name, location, e-mail, phone number, date of birth of yourself or your child and a message. Such information is only collected from you when you voluntarily submit it to Coeliac Society of Ireland, Dolcan House, 78/80 Tower Road, Clondalkin, Dublin 22 D22 N6F6; by filling in forms on our website or by corresponding with us by phone, e-mail or otherwise. By providing us with this information, you express consent to use your information to contact you and talk to you about our services. Our phone calls may be recorded for quality and training purposes only. If you sign up for our newsletter we may occasionally send you information and updates, you can at any time opt out of the newsletter.
• Sensitive Personal Data – pre-assessment questionnaire
  Asides from the our forms we do not collect sensitive personal data through our website. After we have personally spoken to you and you have decided on booking an assessment with you we will send you out a pre-assessment questionnaire. You will be asked to provide sensitive data to allow us to perform the assessment and in order for us to provide our services.
  You do not have to fill out every section if you are not comfortable with. No information will be shared to any third party and all data is treated with highest level of confidentiality. We may only disclose it where you have given explicit consent; we have a legal obligation to do so or in order to protect your health and welfare.
• Non personal information
  When you visit our website, we automatically collect certain non personal information about your device, including information about your web browser, IP address, time zone. As you browse our website, we collect information about the individual web pages that you view, what websites or search terms referred you to the our website, and information about how you interact with our website. This information will only be used for producing anonymous website statistics and will be used to help us with the delivery of the services on the website. This non personal information cannot be used to identify or contact you.

For full details of our cookies and how to opt in/out of their use, see our COOKIE POLICY page.

From third parties:
Where you have given consent, third parties will share data with us, such as fundraising activities from Altruism Ireland, and similar sites or social media sites if you’ve consented to share data via your settings.

What we use it for:
By data protection law, we can only use your personal data if we have a lawful basis to do so, which will be one of the following depending on what we are using your data for:

• When it is in our legitimate interest, or
• When you consent to it, or
• To fulfil a contract we have with you.

A legitimate interest is when we have a valid reason to use your information as part of the maintenance of the Society as an on-going concern for all Members. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is based on the listing below.

Here is a list of all the ways that we may use your personal information.

• Provide you with the member services you have subscribed to, products you have purchased or information you have requested.
• Communicate with you regarding any opportunities to support Coeliac Society of Ireland including activities you have volunteered for or events you have signed up to.
• Administer your financial transactions with us including any fees, donations and processing any related gift aid / reclaim of tax on charitable donations.
• To keep a record of our relationship with you and to help us better inform our services to you in the future.
• Your communication preferences and where available, information on support that is local to you.
• To support the research community for coeliac disease by providing anonymised group data, or personal data only where we have your consent to do so should you wish to participate in any studies.
• To send you third party advertising where we believe the products will support living gluten free and / or related health conditions. We will not provide your personal data to third parties for them to market to you directly.
• If you engage with us via social media, we may in specific circumstances such as competition entry, pass your data to a third party but we will inform you of this before you submit your data so you can choose not to participate.
• In the event you enter your details on one of our online forms but don’t complete the submission, we may contact you to see if we can help with any problems you may be experiencing with our forms or website.
• Profiling our supporters by geographic, demographic and other information from the sources above (see The Data We Collect section) allows us to provide relevant and timely communications and a more tailored service to you. Profiling allows us to focus our resources, maximising the effectiveness of the financial support we receive and allowing us to make appropriate requests for additional support from those who may be able and willing to contribute more.
• If you join on behalf of a child under the age of 18, all our communications and services will be directed to you as the parent/carer to share with your child. We will never contact your child directly until they are over 18.

How we keep your data secure and who processes your data
The Coeliac Society of Ireland is the data controller and will perform the processes above with the support of trusted partners and suppliers, who will be held to the same standards of compliance as we are ourselves. We ensure they store the data securely and are contractually obliged to adhere to all the data regulations required by law.

We currently use third party suppliers to send emails, process payments, operate our website and apps. We only provide them with the data needed to deliver the specific service.

We continually monitor our trusted partners and suppliers to ensure they are adhering to the required standards.
We may need to disclose your data if required to the Gardaí, regulatory bodies or legal advisors. We will only ever share your personal data in other circumstances if we have your explicit and informed consent.

Where you use a third party to provide data to us, they will have their own data protection and privacy policies and we recommend you are aware of these before signing up.

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Our communications with you
There are many ways for you to engage with us. The communications you receive from us will be tailored to the nature of that engagement(s).
By joining The Coeliac Society of Ireland as a member, depending on the option chosen, you will receive some or all of the following essential communications and services containing information on living gluten free and related health conditions and on the campaigning and fundraising activities of the charity should you wish to join in at any point. A full list of all member services is available here.

• Annual Food List with updates throughout the year
• A dedicated Helpline
• Updates on the latest medical advancements on coeliac disease
• Invitations to Society Events
• Discounts and competitions for new coeliac products
• Monthly Ezine with food updates and coeliac community news
• Stronger Together – Together with the Society you can help influence government policy and the availability of affordable gluten-free products
• A dedicated members zone on www.coeliac.ie
• If you wish, you may opt out of any of these key services at any time by logging onto your account on our website or contacting our Helpline on 01-8721471.

We may also contact you by post, in addition to the above, with relevant and timely communications on the work the charity is doing, to give you the opportunity to help us campaign and fund raise for better support for those living gluten free or simply be kept informed of changes in policy and healthcare that may affect you. We believe that by engaging with the charity, you would reasonably expect to be kept informed when opportunities arise, but you may opt out if you don’t feel they are relevant for you at any time.

We will not send these communications by electronic means (including email, fax, telephone) unless you specifically give us consent to do so.

Who we share your data with

We may disclose your personal information to:

• If you request a password reset, your IP address will be included in the reset email.
• Visitor comments may be checked through an automated spam detection service.
• Other service providers such as payment processors, data analysis, contractors or suppliers and IT services (including CRM, website, video and teleconference services.
• Our supply chain partners and sub-contractors, for example couriers.
• Police, law enforcement and security services.

We do not disclose personal information to anyone else except as set out above.

Retention
If you do not wish to continue to be a member of the Society, we will delete your personally identifiable information once four (4) years has elapsed since your membership expired unless you update your communication preferences by going online or contacting the helpline.

We will retain your data to meet any legal and financial requirements. Retaining your data also allows us to support research into coeliac disease.

We are the only organisation in Ireland that has a register of people with coeliac disease, which can help researchers find better solutions to managing, and eventually, curing coeliac disease.

If you would like us to remove your data (except that which we must retain for legal and financial reasons), please let us know via the helpline or online and we will remove it.

Your data and your rights
You have a right to ask for a copy of the information we hold about you. To do so please send a description of what information you would like a copy of, along with proof of your identity to
Membership,
Coeliac Society of Ireland,
78/80 Tower Road,
Clondalkin,
Dublin 22,
D22 N6F6.

We will supply the information as requested without delay or advise you if we are unable to comply for any reason. If you find discrepancies in the information we provide, please advise us by calling the Helpline on 01-8721471 so we can correct them.

You have a right to ask us to restrict or stop processing your personal data, and if it’s not necessary for the purpose you provided it to us for (e.g. administering your membership or processing your donation) , we will do so. At your request, we will erase any data we hold unless it is required for legal or financial reasons if you no longer wish for us to hold or process your data.

From 25 May 2018 with the implementation of the GDPR guidelines, you have enhanced rights over how your personal data is held, processed and stored. It is intended that by complying with these guidelines, Coeliac Society of Ireland will adhere to best practice regarding the applicable Data Protection legislation.

You have the following rights in relation to your personal information:

• the right to be informed about how your personal information is being used;
• the right to receive a copy of any information relating to you without undue delay and at the latest, within one month of receipt of your request free of charge;
• the right to have inaccurate data we may hold about you corrected;
• the right to restrict processing of your personal information where certain requirements are met either permanently or temporarily;
• the right to ask us not to process personal data for marketing purposes;
• the right to erasure of your personal data;
• the right to request that we transfer elements of your data either to you or another service provider in a structured, commonly used, machine-readable format;
• the right to object to certain automated decision-making processes using your personal information;
• the right to complain to the Irish Data Protection Commissioner or seek a judicial remedy in the Irish courts

You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us.

While this Privacy Notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Data Protection Commissioner’s (DPC) website at https://www.dataprotection.ie/docs/GDPR/1623.htm

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us as set out it the “Contact Us” section below.

If you are unhappy with the way we are using your personal information, you can also complain to the Data Protection Commissioner’s Office or your local data protection regulator. We would, however, appreciate the chance to deal with your concerns before you approach the Data Protection Commission so please contact us in the first instance.

Any access request will be responded to within one month of receipt of the request, however this may be extended to up to 2 further months where necessary depending on the complexity of the request. Documentation will be provided free of charge, unless the request is manifestly unfounded or excessive, in which case a reasonable fee may be charged.

Our website may, from time to time, contain links to and from the websites of other networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Changes to our Privacy Policy

Any changes we may make to our privacy policy in the future will be posted on this page, you may also be notified by email. You should visit this page periodically to review any changes to the Privacy Policy.

Contact Us

For more information about our privacy practices or if you have any questions about your data including any requests to exercise your legal rights please contact us by email on contact@coeliac.ie or by mail using the details provided below: Coeliac Society of Ireland, 78/80 Tower Road, Clondalkin, Dublin 22 D22 N6F6

If you have any questions please contact us on 01-8721471 for further information on data protection go to: www.dataprotection.ie

Charity No. 7484. Registered in Dublin, Company No. 367017. Company Limited by Guarantee and not having a share capital.

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